Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Exemption u/s 80-IC - Claim denied as no work was carried at the Baddi Unit - There is no concrete material on record which would suggest that the assessee’s claim was not genuine and no work was carried at the Baddi Unit. The fact that the assessee had one internet connection / AC or inadequate computer facilities or the fact the bank accounts were not maintained at Baddi location is only a matter of perception and nothing conclusive could be borne out of those observations. Assessee had well substantiated its claim of deduction u/s 80-I - AT
Exemption u/s 80-IC - Claim denied as no work was carried at the Baddi Unit - There is no concrete material on record which would suggest that the assessee’s claim was not genuine and no work was carried at the Baddi Unit. The fact that the assessee had one internet connection / AC or inadequate computer facilities or the fact the bank accounts were not maintained at Baddi location is only a matter of perception and nothing conclusive could be borne out of those observations. Assessee had well substantiated its claim of deduction u/s 80-I - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4886 
